Dive Brief:
- Clean energy trade groups, ratepayer advocates and 11 out of 15 states in the Midcontinent Independent System Operator’s territory urged federal regulators on Friday to reject the grid operator’s proposal to fast-track combined large load and generation interconnection studies.
- In general, they said the Large Load Addition Resource Study, or LARS, proposal under consideration at the Federal Energy Regulatory Commission lacks sufficient customer protections. Some also raised concerns that the plan favors vertically integrated utilities over independent power producers.
- Duke Energy Indiana, Entergy utilities and other utilities backed MISO’s proposal. “The LARS filing will provide the region with another efficient, effective, and appropriately tailored tool to address the need to expedite the interconnection of new large loads and the necessary generation to serve them,” they told FERC in a joint filing.
Dive Insight:
MISO proposed the 120-day LARS process earlier this month, proposing to offer it to loads larger than 200 MW and generation that is within the same local resource zone.
There are 10 local resource zones in MISO’s footprint, generally aligning with state boundaries. Under the proposal, MISO would study the planned load and generation at the same time.
MISO’s proposed LARS process is partly in response to FERC’s mid-June finding that its rules related to large loads are inadequate, including for integrating “proximate” loads and generation onto the grid, according to the grid operator’s application.
But the Organization of MISO States told FERC that a majority of its members have “significant concerns” about the proposal, including a lack of protections against transmission cost shifting to existing customers, and potential effects on competition and MISO’s generator interconnection queue.
“LARS cannot become a general alternative to the existing [generation interconnection queue] or provide preferential access to transmission capacity without adequate safeguards for existing queue participants and transmission customers,” OMS said, adding that any LARS-like program should end after five years.
Eleven state utility commissions supported OMS’s comments opposing the proposal. State commissions in Arkansas, Louisiana and Mississippi voted against the critical comments, and filed comments at FERC supporting MISO’s plan.
Plan lacks ratepayer protections
Meanwhile, in separate filings, Google and a coalition that includes the Sierra Club and the Natural Resources Defense Council said the proposal would lead to existing customers paying for network upgrades that are needed for any new loads and generation.
“The lack of cost shifting protections is especially concerning because, despite the benefits — especially speed to power — that LARS would promote, it is structured in a way that threatens Google’s ability to meet its foundational commitment to ensuring that other retail customers do not bear the costs of serving its data centers, including through the Ratepayer Protection Pledge,” the company said.
MISO plans to file a cost allocation framework for LARS projects next month, but “the details of that agreement and how it will protect against cost shifts are open questions, which the Commission cannot simply assume away,” Google said.
Ratepayer advocates representing six states also opposed MISO’s proposal, partly because of concerns about cost-shifting.
Groups air discrimination fears
Under the proposal, MISO would only accept LARS applications from its transmission customers — load serving entities, which are mainly vertically integrated utilities.
The American Clean Power Association and other groups said that requirement would give utilities the ability to favor their own generation at the expense of independent power producers.
“Even an IPP with a direct offtake agreement with the large load must be sponsored by the [load-serving entity’s] application; there is no path for an IPP to deal directly with MISO for purposes of accessing the generator interconnection queue,” ACP and the Southern Renewable Energy Association said in a joint filing.
Even if a LSE agrees to include an IPP in a LARS application, the IPP faces stricter eligibility requirements compared to utility generation, according to the trade groups.
The Solar Energy Industries Association and Advanced Energy United also asked FERC to reject the proposal, which they said “is unduly discriminatory because it allows LSEs to decide if their competitors may participate in the LARS process.”
The Data Center Coalition generally supported MISO’s proposal, but said it is concerned about giving utilities sole access to the process.
“In MISO’s primarily vertically integrated footprint, establishing the LSE as the sole LARS application facilitator narrows the pool of supply that can gain access to expedited Large Load Generation Interconnection Agreements ... to only those projects that are effectively approved by the LSE,” the trade group said.
Utilities support plan
“The LARS proposal is a narrowly tailored but valuable tool that enables the accelerated evaluation and integration of electrically proximate large load and generation pairs and the related identification of more efficient network upgrades,” a group of MISO transmission owners told FERC.
As a permanent plan, the LARS proposal will provide a long-term market signal for pairing new large loads and generation for at least 15 years, the utilities said.
Entergy and Cleco Power urged FERC to approve the plan.
“Making LARS a permanent process is appropriate because it provides needed, long-term regulatory and financial certainty required to site and finance large load-and-generation pairings, and it includes structural limits that keep the process bounded in every cycle,” they said in a joint filing.
Correction: This story has been updated to correct the type of load and generation that would be eligible for the fast track process.
